Immediately upon arrival of all active locations where well servicing/workover, completion or plugging operations are occurring;

Immediately upon arrival on any location where venting or flaring operation are occurring;

Immediately upon arrival any location to inspect, witness, or investigate any oil spill; and

During any other hazardous operations identified as requiring its use and noted on a Risk Assessment.

The FRC must cover the upper and lower body, and the outer most layer of clothing must always be flame resistant.

When a company has a written policy that exceeds the above minimum requirements for FRC, we encourage BLM employees to comply with company policy in order to demonstrate our concern for safety. All BLM employees must comply with the minimum requirements stated above. Attachment 1 provides additional guidance for the selection of FRC and required training in its use.

Timeframe: Effective immediately.

Budget Impact: If the BLM has not already purchased FRC for individuals, estimated costs associated with the initial purchase are $800 - $1,000 per person. For FY2011, the WO

provided cost codes to cover costs not already absorbed by the States. We estimate annual replacement/maintenance costs at $300 - $600 per person.

Background: On March 19, 2010, OSHA issued a memo clarifying the need for personal protective equipment (PPE), specifically FRC, on oil and gas well drilling, servicing, and production operations due to the potential for flash fires. Recently, operators have denied access to some field inspectors for operations on which drilling was at or near a gas zone because they lacked the required PPE. The BLM is responsible for the safety of our employees and must provide the required safety equipment to ensure their protection while conducting field work.

Manual/Handbook Sections Affected: The BLM Handbook 1112-1, Safety and Health Management will be amended during the next update.